Business income classification governs receipts arising from financing and allied business activities, not income from other sources.

Receipts arising from an assessee's financing and allied business activities were held to fall under the head profits and gains of business or profession, because the income was found to have arisen from business operations and not from a separate source outside the business head. The revenue's treatment of the receipts as income from other sources was rejected on the facts recorded, as the assessee's business character of the receipts remained determinative.

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Issues: Whether the receipts earned by the assessee were liable to be assessed as income from other sources or as profits and gains of business or profession.

Analysis: The assessee had shown the receipts as business income and asserted that it carried on financing and allied business activities. The revenue authorities treated the receipts as income from other sources on the footing that the assessee had not carried on business in the relevant year. On the facts recorded, the income was found to have arisen from the assessee's business activities and not from a source falling outside the business head.

Conclusion: The receipts were assessable under the head profits and gains of business or profession and not under the head income from other sources.

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